Trade Regulation Updates

CPSC Introduces New eFiling Requirements and Implementation Details

June 19, 2026

On June 16, 2026, the Consumer Product Safety Commission (CPSC) announced that certificates of compliance must now be filed electronically and directly to CBP. Importers have been required to maintain certificates of compliance since 2008, but the method of reporting is now entirely electronic and made directly to CBP.

The mandatory full implementation date for these electronic filing regulations will take effect on July 8, 2026, for most regulated consumer products, and January 8, 2027, for products coming out of a Foreign Trade Zone.

Affected Commodities: Over 600 Harmonized Tariff Schedule (HTS) codes have been flagged as being affected by this regulatory change. Notably, importers are responsible for identifying which goods are affected based on the actual product type rather than relying solely on the HTS classification. You are encouraged to work closely with your broker to identify goods that may be affected by this regulatory change.

CPSC eFiling Requirements and Implementation Details

  • Importers now have two distinct pathways to electronically transmit the required seven data elements.
    • Pathway A: CPSC Product Registry IDs (Reference Filing)
      • This is best for high-volume or repeat importers. Importers pre-upload and certify their data directly in the secure CPSC Product Registry prior to importation.
      • Then, the customs broker files a brief Reference PGA Message Set using your Certifier ID, Product ID, and Version ID.
    • Pathway B: Full Data Submission (Direct Entry)
      • This pathway is best for low-volume or one-off importers. Importers of this kind bypass the registry entirely and provide the full certificate data set on their commercial invoices or supporting documents.
      • Your customs broker manually types all seven data elements into the Full PGA Message Set at the port of entry.

Importers utilizing the Product Registry must generate an entirely new certificate if there is a change in the product's materials, the testing laboratory, the manufacturer, or the "last test date."

The system utilizes an invitation-based system that allows brokers to review and manage data. However, while brokers are responsible for transmitting data to CBP, they still do not validate it.

To begin your CPSC Product Registration, click here

For additional information on eFiling, including frequently asked questions, click here.